SUPPLIER CODE OF CONDUCT

Version 1.0 · Effective 2 November 2026

Purpose

ECOFACTOR supplies EV charging equipment and operates charging networks and software. The quality, safety and integrity of what we deliver depends on our suppliers. This Code sets out the minimum standards we expect from every supplier and partner that works with us.

In this Code, “ECOFACTOR”, “we” and “us” mean the companies operating under the ECOFACTOR brand: ECOFACTOR Sp. z o.o. (Poland), ECOFACTOR TECH UK LIMITED (United Kingdom) and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (Ukraine). “Supplier” means any supplier of goods or services, contractor, installer, delivery partner or other business partner.

Suppliers must comply with this Code in addition to the law and their contract with us. We expect suppliers to apply equivalent standards to their own suppliers and subcontractors who work on ECOFACTOR business.

1. Legal compliance

Suppliers must comply with all laws that apply to them in each country where they operate. Where this Code and the law differ, the stricter standard applies to the extent permitted by law.

2. Labour standards and human rights

Suppliers must respect internationally recognised human rights, including the ILO fundamental principles and rights at work. In particular, suppliers must:

• pay at least the applicable minimum wage and all legally required benefits, on time and with clear pay slips;
• comply with legal limits on working hours, rest periods and overtime;
• provide every worker with a lawful written contract or equivalent document in a language they understand;
• treat workers with dignity and respect, without harassment, abuse or discrimination;
• respect workers’ freedom of association and right to collective bargaining, as provided by law.

3. No forced labour, trafficking or child labour

• No forced, bonded, indentured, trafficked or involuntary prison labour of any kind.
• No retention of workers’ identity documents, passports or work permits, and no deposits or recruitment fees charged to workers.
• Workers must be free to leave their employment on reasonable notice.
• No child labour: no worker below the minimum working age under local law or the ILO standards, whichever is higher. Workers under 18 must not perform hazardous work, including night work or work with high voltage.

4. Health and safety

Suppliers must provide a safe and healthy workplace and, in particular:

• assess and control risks, especially for electrical work, work at height, manufacturing, handling of hazardous substances and work on public sites;
• ensure that people working on our chargers and installations are trained, qualified and, where the law requires, certified or accredited for the work;
• provide suitable personal protective equipment free of charge;
• report to us without delay any serious accident, incident or near miss connected with ECOFACTOR work or products.

5. Product quality and safety

Goods and components supplied to us must meet the agreed specifications and all applicable safety, technical and chemical requirements, including restrictions on hazardous substances in electrical and electronic equipment. Suppliers must provide the declarations, test reports and technical documentation we need to show that our products comply with the law, and inform us immediately of any defect or safety issue.

6. Environment

Suppliers must comply with environmental laws and permits and should work to reduce their environmental impact, including energy use, emissions, waste and the use of hazardous substances. Where relevant, suppliers must provide the information we need to meet our obligations under applicable rules on waste electrical and electronic equipment, batteries and packaging. Environmental claims about goods supplied to us must be accurate and supported by evidence.

7. Responsible sourcing of minerals

Electronic components and metals may contain tin, tantalum, tungsten and gold, and batteries may contain cobalt, lithium, nickel and natural graphite. Suppliers of such components must:

• take reasonable steps, in line with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, to avoid sourcing materials that finance armed conflict or are linked to serious human rights abuses;
• on request, provide information about the origin of these materials and the smelters or refiners in their supply chain;
• where our products contain batteries, provide the information we need to comply with Regulation (EU) 2023/1542 on batteries and waste batteries.

8. Anti-bribery and corruption

Suppliers must not offer, give, request or accept bribes, kickbacks or any improper advantage, including facilitation payments, whether to or from our employees, public officials or anyone else. Gifts and hospitality to ECOFACTOR employees must be modest and occasional and are never allowed during a tender or negotiation. Suppliers must keep accurate books and records. Our standards are set out in our Anti-Bribery and Corruption Statement.

9. Conflicts of interest

Suppliers must tell us about any family, financial or other relationship with an ECOFACTOR employee that could influence our dealings with them.

10. Sanctions, export controls and trade compliance

Suppliers must comply with the sanctions and export control rules of the European Union, the United Kingdom, Ukraine and the United Nations, and with other sanctions regimes that apply to them. In particular, suppliers must:

• not be, or be owned or controlled by, a sanctioned person or entity, and tell us immediately if this changes;
• not supply us with goods, components, software or services originating in, or routed through, a country or person in breach of applicable sanctions, including the restrictive measures adopted in response to Russia’s war against Ukraine;
• provide accurate information about the origin, customs classification and export control status of what they supply;
• comply with any restriction on re-export that we pass on to them.

11. Data protection, confidentiality and information security

Suppliers must protect personal data and confidential information they receive from us, use it only to perform their contract and comply with applicable data protection law, including the GDPR and the UK GDPR. Suppliers who process personal data on our behalf must sign a data processing agreement. Suppliers of software, connected hardware or IT services must apply appropriate security measures and notify us without undue delay of any security incident affecting ECOFACTOR data, products or systems.

12. Fair business

Suppliers must compete fairly, comply with competition law and not exchange competitively sensitive information with our competitors or other suppliers in connection with our tenders.

13. Audit and cooperation

Suppliers must:

• answer our questionnaires and requests for information truthfully and on time;
• allow us, or an independent auditor appointed by us, to verify compliance with this Code, including through documents and site visits on reasonable notice;
• cooperate in any investigation of a suspected breach;
• tell us promptly if they become aware of a breach of this Code in their own operations or supply chain.

14. Consequences of non-compliance

If a supplier does not meet this Code, we will normally work with the supplier on a corrective action plan with agreed deadlines. Serious breaches — in particular forced or child labour, bribery, sanctions violations, serious safety failures or serious environmental damage — or a failure to correct a breach may lead to suspension of orders or termination of the relationship, in line with the contract and the law.

15. Raising concerns

Suppliers, their workers and anyone else can report a suspected breach of this Code or any unethical conduct involving ECOFACTOR to info@ecofactor.eu, including anonymously. Details are on our Report a Concern page (https://ecofactortech.com/legal/report-a-concern/). We do not tolerate retaliation against anyone who reports in good faith, and we expect suppliers to protect their own workers who raise concerns.

Document control

Version 1.0 · Effective 2 November 2026 · Owner: Legal (in-house) · Approved by: adopted by ECOFACTOR Sp. z o.o. (Management Board), ECOFACTOR TECH UK LIMITED (directors) and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (Director)